Calcote v. United States

OPINION

BARLOW, District Judge.. This is a suit for refund of income taxes, pursuant to 28 U.S.C. § 1346(a) d).

On August 28th, 1968, the parties submitted this action to the court for determination upon a stipulation of facts which included the following in relevant part:

Chem-Atom Associates, of Princeton, New Jersey, Inc. (hereinafter Chem-Atom) was a holding company which owned, among other stock, eighty per cent (80%) of the stock of Aero Chem Research Laboratories, Inc. (hereinafter Aero Chem). Prior to September, 1960, the issued common stock of Chem-Atom was owned as follows:

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